DRC-2010-005578 - 0901a068801cd722

DRC-2010-00557B
Department of
Environmental Quality
Amanda Smith
Execulive Direcior
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
State of Utah
GARY R. HERBERT
Governor
GREG BELL ,
Lieutenant Governor
October 11,2010
Certified Mail
(Retum Receipt Requested)
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp (DUSA)
, 1050 17* Street, Suite 950
Denver, CO 80265
Dear Ms. Tischler:
SUBJECT: September 2, 2010 DUSA Response Letter, White Mesa Uranium Mill- New
Decontamination Pad [NDP]; the Proposed White Mesa Mill Tailings Management System
and Discharge Minimization Technology (DMT)Monitoring Plan (DMT Plan), 9/70
Revision: Denison-10. ]; the Proposed Cell 4A BAT Monitoring, Operations, and
Maintenance Plan (Cell 4A O&M Plan), 8/10 Revision Denison 1.6; the May 10, 2009
[2010] DRC Letter on the NDP: Comprehensive Comnients on the Proposed Revised
DMT Plan and the Proposed Revised Cell 4A O&M Plan, which include revisions for the
NDP and other items.
We have reviewed the subject response letter from DUSA dated September 2, 2010. This letter was
written in response to our request for information regarding the New Decontamination Pad (NDP) dated
May 10, 2009 (actual date was May 10, 2010).
You make reference to a DUSA submittal letter, dated August 4, 2010, that contains infonnation pertaining
to the NDP. We located two letters from DUSA to DRC with that same date. In the discussion that
follows, the DUSA letter of that date, containing information related to the NDP, will be referred to as the
August 4, 2010-A letter. We also acknowledge that in your September 2, 2010 letter you request that the
DRC ignore the DMT Plan (Revision 10.0) included in the DUSA August 4, 2010-A letter, therefore, our
review of the DMT Plan Revision 10.0 document has ceased. However, our review has continued on a
separate document in the August 4, 2010-A letter, i.e., the subject Cell 4A O&M Plan, 8/10 Revision
Denison 1.6. Our comments on that document are given later in this letter.
Our letter of March 30, 2010 is our last known DRC approval of revised DMT and Cell 4A O&M Plans. It
approved DMT and Cell 4A O&M Plan revisions, separately known as 3/10 Revision: Denison-7, and
revision 3/10 Revision Denison 1.4, respectively.
Contingencv Plan (Revision 3)
In the subject September 2, 2010 letter, DUSA provided a proposed Revision 3 of the Contingency Plan.
This was provided in response to our subject comment letter of May 10, 2010. However, our response
195 North 1950 West • Salt Lake City, UT
Mailing Address; P.O. Box 144850 • SaJt Lake City, UT 84114-4850
Telephone [phone]-Fax (801) 533^097'T.D.D. [phone]
www.deq.ittah.gov
Printed on 1(X)% recycled paper
Page 2
regarding the Contingency Plan will not be addressed in this letter, but will be addressed under separate
cover. Review of that plan will proceed independently, and will not be tied to the use of the NDP. For
reference, the third paragraph and Section 2.a.l of the subject September 2, 2010 DUSA letter specifically
address the contingency plan comments in our May 10, 2010 letter.
We have several comments on the Proposed DMT Plan and Cell 4A O&M Plan, as follows:
Comments on the Proposed DMT Plan (Revision 10.1, refer to the black-line copy):
1. Paragraph 3. l.e.i.D. The end of the third sentence should be changed to read, ". .. standing water
shall not be less than 6.2 feet."
2. On page 28 of 48 in Appendix A, entries:
a. Item numbered as one on that page should state Pond and Beach elevations (as per
approved DMT Plan 3/10 Revision: Denison-7).
b. For Cell 3 should be deleted (as per approved DMT Plan 3/10 Revision: Denison-7).
c. For Cell 4A an item (d) should be added (per the foregoing reference).
3. Per our letter dated April 29, 2010, comment two, where we previously requested that in Appendix
A of the DMT Plan, Table 11. Operational Systems, that a line be added in the table for any
observable FML liner damage at any disposal cell. Please add this line.
4. For reference, on page 34 of 48 the bottom two new paragraphs of the black-line copy regard storm
water. The record of these storm water related inspection items will need to be available for the
annual storm water inspections held at the mill.
Comments on the Proposed Cell 4A O&M Plan (Revision 1.6):
A. The list of Attachments on the last page of this plan needs to be revised. It does not include the
revisions for this page, which were proposed in the versions submitted in the DUSA letters of
December 11, 2008 and May 26, 2009, Please update and complete.
B. The actual attachments need to be included with the proposed plan. This would be a change to the
attachments included with the current approved version. Cell 4A O&M Plan 3/10 Revision
Denison 1.4. Please submit.
Please review the above comments, and submit the requested information. Please include complete final
copies of the revised subject plans, given new and unique version numbers. Per your email of October 11,
2010, you committed that DUSA would fully respond to the above with 30 days of receipt of this letter. If
you have any questions on the above, please contact me.
Sincerely,
David A. Rupp, P.E
Geotechnical Services
DAR: dr
Cc: Harold R. Roberts, DUSA
Phillip Goble, DRC
F:\DUSA\ GWDPermil\NDP\Fnl Cmtsl0-2010.doc